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Pundit’s Mailbag — Small Farmers Have More At Stake With Food Safety

Jim Prevor’s Perishable Pundit, December 4, 2007

Our piece, Chefs Collaborative Opposes Leafy Greens Marketing Agreement, brought a firestorm of protest from smaller growers, including this letter:

You should have put a bit more thought into your assertion that small outbreaks of food borne illness are not noted or acted on by authorities. You are confusing the level of publicity an outbreak rises to with the number of outbreaks that have been reported and acted on.

Being in the Pundit business, though, it’s appropriate that that’s how you would look at it. Small outbreaks are acted on by local/state health authorities all the time. A large outbreak is actually just a collection of small outbreaks. These small outbreaks are noted by the local emergency room physicians and are then reported to the CDC. When enough small outbreaks occur with the same casual factors identified, then you have a big outbreak. But the initial reporting is always done by the local personnel.

When viewed in the above light, the flaw in your logic becomes apparent. I personally know of two outbreaks reported with 6 and 4 illnesses, in different parts of the country, that resulted in recalls of all suspected product on the authority of the County and City health officer. Neither made the news so they won’t show up on Google to this day. Nor do they show up on the FDA websites!

If the local authorities were not doing their jobs, then no outbreaks, large or small, would ever be reported. But they are, and that’s why you hear about the public swimming pool water, or the church social, or the local diner that caused half a dozen people to report to the local hospital. It’s true that the number of people reported in any outbreak is significantly smaller than the number made ill. But it doesn’t follow that a small outbreak only occurs among folks that don’t report.

It would be absurd to think that just because an item of produce is local that it can’t cause an illness outbreak. But it’s also absurd to believe that just because it’s local, it doesn’t get reported. Think about it, if a farmer’s market or some other localvore venue was identified as a possible source in a food borne illness outbreak, the news would probably be national even in the smallest outbreak. The press loves to attack so-called liberal values and loves to puncture belief balloons of the dreamy-eyed consumer.

I think it’s significant that you could not find a local farm source outbreak to actually report on. You must have tried or you wouldn’t be doing your due diligence.

All of us in the small farm community are concerned about food safety. If we make our customers ill, then we are out of business. No small farm could survive even one recall and come back. We know our customers personally, in some cases by name, and we live in the community we serve. There is no accountability better that.

We are not opposed to food safety plans for small producers, but do you really believe that a food safety plan administered from Washington DC is going to be anything but a bureaucratic nightmare?

On a final note, the gist of your piece seems to rest on the idea that opposing the LGMA is short-sighted. You go on to say that the world needs HACCP plans. I don’t find a HACCP plan in the LGMA GAP/Metrics. Most every privately audited food safety plan is much more robust than the GAP/Metrics.

If money and HACCP plans equaled food safety in a proportionate basis, then how in the world do we get the large company recalls that we continue to see? Companies large and small are spending millions on food safety, and I believe America has a very safe food system, but the illnesses from those very same companies keep coming.

— Kenneth Kimes
New Natives
Freedom, California

We appreciate Ken’s letter. His company seems to do interesting things. New Natives describes itself this way:

New Natives farm is nestled in a valley on the central coast of California. Over the last 20 years we have grown thousands of pounds of sprouts, using good organic seed, natural sunlight, clean water, and nothing more. Growing sprouts of high quality, using the natural elements is very important to us. We sell locally at farmers markets and natural food stores. New Natives sprouts are known for flavor, quality, and integrity

The company also seems to sell organic seeds for sprouting, which sounds like fun, and the Pundit might be tempted to buy some to sprout with the Jr. Pundits, but we hesitate because on its website, New Natives describes the seeds this way:

These organic seeds are sleeping peacefully and have not been disturbed with chemicals, irradiation, genetic modification, or other invasive processes.

This worries us a bit, as while Ken’s seeds are “sleeping peacefully,” the ones watched over by frequent Pundit contributor Bob Sanderson of Jonathan’s Sprouts are being “triple tested” for safety. You can see it all here. Then Jonathan’s does more testing on the crop. We wonder if it makes food safety sense to grow this crop all on our own?

Still Ken is intriguing — doing things such as “…experimenting with a mustard seed variety developed at the University of Idaho that works as an organic fertilizer after its oils are extracted for biodiesel.” We would like to break bread with him some time.

Yet, we confess to always being astonished at how quick people are to assume that people who disagree with them just haven’t thought things through. Considering that we have written hundreds of thousands of words on food safety for over two decades, to accuse us of needing to “put a bit more thought” into the issue seems downright odd.

As it happens, if you read Ken’s letter you notice that there are no quotes in it — that is because we never actually said the things he accuses us of saying. For example, at no point in our article do we say that “…small outbreaks of food borne illness are not noted or acted on by authorities.”

Lest anyone drew the same inference, let us state our point clearly: The authorities should act and often do act on every case of foodborne illness brought to their attention. However, we made two specific points:

1) The math of the matter is such that many small outbreaks will simply be very hard to trace back to a particular producer.

A plant the size of the Natural Selection Foods plant implicated in last year’s spinach crisis would probably produce around ten million servings a day. Obviously we have no way of knowing how much of the plant’s production had pathogens on it and recognize that the plant can produce multiple items.

Equally, a small producer might have many products to sell and we can’t know how much of his production has pathogens on it.

We do know that we were able to identify 300 people who got sick or died as a result of the contaminated spinach. So this gives us our ratio: 300 identified illnesses or deaths for each 10 million servings produced — when there is a pathogen contamination existing.

Obviously this is subject to change, based on the extent and intensity of the pathogen, but, assuming the local producer is no worse on food safety than the plant last year, this gives us something to work with.

And what it tells us is that if a local farmer is cutting his crop and going to a farmer’s market and his crop is equally contaminated to what that day’s production was last year, we would expect his crop to result in less than one tracked-back illness — unless our local grower sold at least 33,333.34 servings that day at the farmer’s market. The 33,333.34 number comes simply by dividing 10,000,000 servings by 300 known affected people.

Now these are just statistics and the actual events will differ, so some poor farmer could get six people sick and it could be tracked back. But that is not going to be typical.

Our guess is that this significantly understates the amount of product that a local grower would have to sell to expect that a foodborne illness will be tracked back.

First, many of those tracked back were identified because the people who got sick or died had bags of product in the refrigerator. Without those bags, the number would have surely been less both because consumers might forget what they had eaten and because a definitive tie could be made from product testing.

Second, the enormous publicity and the involvement of big business such as Dole and Natural Selection Foods encourages people to go to the doctor both because they hear there can be a real problem and because some smell a chance for a settlement. If there had been a news blackout on the spinach crisis and the FDA never issued its advisory, we think the 300 number would have been much lower.

Now, even if we have one sick person who reports himself to a doctor or hospital and even if the person’s symptoms are correctly diagnosed, the limits of survey methodology make it far less likely that an individual illness will ever be tracked back to a specific producer.

The way our surveys work is that we survey healthy people and ascertain what is normal — then, if people come in sick, we can give the same survey. If the base survey indicates that 10% of the population eats a spinach salad every day and 99% of the sick people coming into the hospital ate a spinach salad, that is what tips us off as to where to investigate. But if only one person gets sick, the questionnaire isn’t very useful because we can’t ascertain statistical anomalies.

So the point is obvious: we will always expect to track back more foodborne illness to large shippers and chain restaurants than we will to small growers and independents — even if they are all equally proportionally responsible for foodborne illness.

2) The safety of fresh-cuts cannot be assessed by comparison to bulk product.

Yes, theoretically, blends will increase risk. Take 50,000 pounds of radicchio with a pathogen on it, blend it with 950,000 pounds of Romaine, and you have a million pounds of contaminated product. Although, of course, how much actually will get to the public depends on the effectiveness of our washing procedures — it might be zero.

However, the risk of blending in a fresh-cut plant is just one possible risk. If to avoid that risk, a restaurant, for example, wishes to consider buying all bulk and chopping it up and mixing it in a salad in house — otherwise known as processing and blending — it has to evaluate the food safety risk of all those manual steps. Are the knives and cutting surfaces sanitary, do workers properly wash their hands and under their nails after using the rest rooms, do people take off if they are sick, etc.? The evaluation, in other words, has to include both the product and the processing — wherever the processing may be done.

*****

We are sure that small farmers would like to sell safe food. That is not the issue. The issue is whether food safety standards should be compromised because they are difficult to meet.

The gist of the complaint here is that if a large farmer owns a 100,000-acre ranch surrounded by cattle feeding lots, the requirement to maintain a buffer zone is an inconvenience and expense but not business-threatening. However, a farmer who owns 4.3 acres surrounded by cattle feed lots may be driven out of business by such a requirement.

To which we respond: We are sorry, genuinely sorry, but we now know that that piece of land is simply not an appropriate place to grow fresh food.

As our correspondent points out, the Leafy Greens Marketing Agreement metrics are not a HACCP plan. But small growers are not proposing that they be allowed to impose more rigorous standards upon themselves. The metrics allow for that anyway.

We certainly think small growers deserve a chance to critique and have input on the GAP metrics. But that input should be on a scientific basis — not related to marketing.

Right now the smaller growers and the chefs we were writing about are not critiquing the metrics. They are just asking for an exemption from them.

If the Chefs Collaborative wanted to hire some PhDs in agronomy and asked if its committee could submit suggestions for modifications of the metrics, well, this columnist would be the first one on their side.

But to say that food safety standards should be abandoned because they are difficult to adhere to and therefore some people will go out of business and some buyers will have to buy less conveniently — that is hardly an argument at all.

We appreciate Ken’s letter and the opportunity it gives us to clarify our point.

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